Introduction

DNB regularly and at least annually publishes a supervisory calendar for various financial companies it supervises. For insurance companies, DNB has published the 'Supervisory Calendar Insurers 2025' (Toezichtkalender Verzekeraars 2025), in which DNB describes the sector-wide supervisory activities and related supervisory themes it will consider in 2025. DNB will also publish a supervisory calendar for each insurance company with institution-specific supervisory activities. This version can only be accessed by the insurance companies via the DNB portal (found via My DNB).

Besides the supervisory calendar 2025, DNB also published the annual 'Supervision in Focus 2024-2025' (Toezicht in Beeld 2024-2025) in November this year. In this document, DNB discusses more generally the developments of last and coming year in various supervised sectors including the banking and insurance sector.

Below, we discuss the relevant sector-wide supervisory activities for insurance companies for 2025. Where relevant, we will also include insights from the 'Supervision in Focus 2024-2025'.

Sector-wide supervisory activities for (re)insurance companies

In 2025, DNB will involve three strategic sector-wide themes in its supervision on insurance companies. These are:

  1. System of Governance.
  2. Digital Operational Resilience Act (DORA) and Cybersecurity.
  3. Quality calculation Standard formula.

According to DNB, System of Governance (SoG) assessments offer insurance companies insight to design governance and internal supervision more effectively. In 2021, DNB provided some suggestions for the best approach and design.

By means of a thematic survey, DNB aims to determine effectiveness. The thematic survey therefore aims to (i) give DNB insight into how different insurance companies conduct and use the SoG assessment; (ii) establish guidance and good practices that enable insurance companies to enhance the effectiveness of the assessment; and (iii) where relevant, provide guidance to insurance companies, including expectations regarding follow-up steps.

DORA will apply to in-scope financial entities including (re)insurers from 17 January 2025. Within this longer-term theme, DNB has identified the following focus areas for 2025:

  • Oversee the management of IT, cyber and outsourcing risks in line with DORA.
  • Actively monitor concentration risks within the insurance sector through information registers of financial entities to be received.
  • Better understand the signals coming from current threat assessments and the SBA-IB 2024 analysis. This includes looking at data management, data retention, application lifecycle management and cryptographic key management.

DNB plans to conduct further investigations at selected insurance companies in the form of risk assessment interviews and deep-dives. This is expected to take place from Q2 2025. In addition, DNB has scheduled to request the required information registers submitted by financial entities, in February 2025.

Another thematic investigation in 2025, concerns the calculation of the capital requirement with the standard formula which will focus on the quality and accuracy of the data, tools and processes used by insurance companies in this regard. In that context, DNB aims to request information from solo insurance companies, in Q2 2025. Subsequently, DNB will select four insurance companies to perform a deep-dive. The selected insurance companies are expected to be notified in early Q3 2025, after which the deep-dives will take place later that quarter.

Other focal points and regular monitoring activities

In addition, DNB will also focus on a number of longer-term (supervisory) topics in 2025. We provide a brief overview below:

  • Sustainability in supervision: DNB aims to further integrate 'sustainability' into her supervision. To this end, the SBA NFR will be expanded to include questions on embedding sustainability the day-to-day operations of insurance companies. In addition, a number of insurance companies are requested to indicate how sustainability is integrated into their (risk) organisation and share the performed (materiality test / risk analysis) with DNB.
  • AI at insurance companies: In view of the AI Regulation, DNB has already started its investigations in 2024 to find out how AI is implemented by insurance companies, including management measures on associated prudential risks. Based on these outcomes, DNB intends to further shape its supervision of AI by soliciting industry-wide information and conducting in-depth research at a selection of insurance companies.
  • Expected Profits Included in Future Premiums: DNB will investigate the so-called Expected Profits Included in Future Premiums (EPIFP), analysing assumptions and methodologies for different subsectors.
  • Future Pensions Act: The Future Pensions Act came into force on 1 July 2023 and insurance companies have until 1 January 2028 to comply with it. DNB continues to monitor the transition and implementation of the new pension rules through individual and industry-wide surveys focusing on buyouts, risk appetite and investment strategies.
  • Resolution plan: DNB makes an annual information call on supervisory activities in the context of resolution planning. For 2025, DNB aims to operationalise the resolution plan (through playbooks). At the same time, DNB is working on a framework for assessing resolvability so that DNB can monitor the progress of relevant insurance companies.
  • Implementation revised Solvency II Directive (Directive): The revised Directive was agreed in 2024. Further implementation is currently taking place in lower-level regulations. DNB encourages the insurance industry to prepare for implementation in 2026. In that context, DNB expects that the implementation of the Directive will also have her attention in 2025.

Contact

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